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NY J82682

April 18, 2003

CLA-2-72:RR:NC:1:117 J82682


TARIFF NO.: 7212.40.1000

Mr. E. Thomas Watson
Parker Poe Adams & Bernstein
Three Wachovia Center, Suite 3000
401 South Tryon Street
Charlotte, NC 28202-1935

RE: The tariff classification of clad and PTFE coated steel strip from Japan.

Dear Mr. Watson:

In your letter dated March 12, 2003 on behalf of Oiles America Corporation (“Oiles”), you requested a tariff classification ruling. Representative samples of the products to be imported were submitted with your ruling request.

The products to be imported are known as “Techmet” and “Drymet” steel strips. These Grade 1012 carbon steel cold-rolled strips measure less than 150 mm in width and will be imported in coil form. Both strips are flash plated with copper on both sides and then clad on one side with a layer of bronze powder containing 9-12% tin, 88-91% copper and a maximum of 0.30% other elements that is sintered to the copper surface. The bronze layer is then coated with a layer of a plastic compound primarily containing polytetrafluoroethylene (“PTFE”). The “Techmet” and “Drymet” strip material will ultimately be used to make self-lubricating bushings that are sold to the automobile industry for incorporation into a variety of friction points in automobiles.

The applicable subheading for the “Techmet” and “Drymet” steel strips will be 7212.40.1000, Harmonized Tariff Schedule of the United States (HTS), which provides for flat-rolled products of iron or nonalloy steel, of a width of less than 600 mm, clad, plated or coated, painted, varnished or coated with plastics, of a width of less than 300 mm. The rate of duty will be 0.3 percent ad valorem.

Even though the “Techmet” and “Drymet” steel strips are clad, the relevant Explanatory Notes to the HTS state that products subjected to more than one type of coating, plating or cladding are to be classified according to the last process.

On March 5, 2002, President Bush proclaimed additional tariffs and quotas on a number of steel mill products for a period of three years. Products classified under HTS subheading 7212.40.1000, unless specifically excluded, are subject to additional duties. See subheadings 9903.73.07 through 9903.73.23, copy attached. Your product, described in subheading 9903.79.80 and enumerated in U.S. note 11(c)(ccxcix) is exempted from these additional tariffs. At the time of importation, you must report this Chapter 99 number in addition to the Chapter 72 number listed above.

The Proclamation is subject to periodic amendment of the exclusions, and the additional tariffs are reduced in the second and third years of the program, so you should exercise reasonable care in monitoring the status of goods covered by the Proclamation.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).

A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Paula Ilardi at 646-733-3020.


Robert B. Swierupski

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